SBA loans over $10 million are already possible right now — before this bill passes — using SBA 504 structures and creative 7a lending, and you don’t have to be a manufacturer.
The Made in America Manufacturing Finance Act passed the U.S. House unanimously on December 1, 2025, and awaits a Senate vote. If it becomes law, qualifying small manufacturers would see their SBA loan ceiling double — to $10 million on both the 7a and 504 sides. Under current law, a manufacturer with 10% down can finance a project up to $13.75 million. If this bill passes, that ceiling jumps to $25 million — same structure, same down payment. But as I’ll explain below, $10 million is already a baseline in several ways, not just a future possibility.
Last updated: May 1, 2026. The bill remains pending in the Senate. This post will be updated when there is a vote.
Key Takeaways
- ✅ SBA loans over $10 million are already possible — without the new law — using the 504 program and/or creative 7a lending. You don’t have to be a manufacturer.
- 🚀 If the Made in America Manufacturing Finance Act passes, $10 million becomes the new normal for qualifying small U.S. manufacturers under both programs — but $10M should already be thought of as a baseline for reasons explained in this post.
- 🧱 504 loans already support projects over $20 million for commercial real estate and equipment-heavy businesses. If the law passes, this could be bumped to approximately $40 million for manufacturers.
- 🔁 Some lenders currently fund $7–9M using creative SBA 7a loan structures — right now, without any new legislation.
- 🔓 U.S. manufacturers can currently finance multiple projects in the $15–25 million range using the 504 program’s per-project stacking rule.
- ⚠️ The “small manufacturer” definition in this bill is stricter than existing SBA rules — all production facilities must be in the United States. Any overseas production disqualifies the borrower from the new $10M ceiling.
What Would the Made in America Manufacturing Finance Act Actually Change?
The Made in America Manufacturing Finance Act of 2025 is a bipartisan bill designed to boost U.S. small manufacturers by expanding their access to affordable capital. In early December 2025, the U.S. House of Representatives unanimously passed this act (H.R. 3174), which would increase the maximum SBA loan for small manufacturers — for 7a loans from $5 million to $10 million, and for 504 second loans from $5.5 million to $10 million.
Keep in mind that the SBA 504 loan is actually a 2nd mortgage or loan that accounts for just 30–40% of the total financing possible when using the SBA 504 program. This is important to understand, especially for small or mid-sized manufacturing businesses, because this new higher loan limit could allow “SBA 504 loans” that support total projects in the $30–40 million range or even higher for stronger borrowers — because the new higher SBA loan limit would allow lenders to offer 504 first mortgages of between $15M and $25M at 50–60% loan to value/loan to cost.
It should also be noted that SBA 504 projects in the $20M–$25M range are currently possible for all types of businesses — not just manufacturers — and some SBA 7a lenders will routinely lend between $7M and $9M for stronger borrowers in many industries, in spite of the 7a’s current “maximum” of $5 million.
| Program | Current Limit (Manufacturers) | Proposed Limit | Max Total Project (10% down) |
|---|---|---|---|
| SBA 504 second loan | $5,500,000 | $10,000,000 | $25,000,000 |
| SBA 7a | $5,000,000 | $10,000,000 | N/A (direct loan, all-in) |
| SBA 504 — standard non-manufacturer | $5,000,000 | No change | $12,500,000 |
Can Manufacturers Finance Projects Over $10 Million Right Now — Before the Bill Passes?
Yes — and this is the point that tends to get buried in coverage of the pending legislation. Manufacturers have several meaningful advantages under current law that are worth using today.
Additionally, manufacturers have the added benefit of being able to access funding on a per-project basis right now, due to the current SBA rule that allows manufacturers to have multiple $5.5 million 504 seconds as long as each is financing a different project. In real terms, a U.S. manufacturer can have multiple 504 loans at one time — each 2nd loan up to $5.5 million — meaning a manufacturer could currently have multiple projects of $16+ million financed with 90% leverage through the SBA 504 loan program.
Current Law — What a Manufacturer Can Finance Per Project Today
| Component | Current Law | If Bill Passes |
|---|---|---|
| SBA 504 second loan (~40%) | $5,500,000 | $10,000,000 |
| First mortgage (~55% LTV) | $9,000,000 | $12,500,000 |
| Down payment / equity (10%) | $1,620,000 | $2,500,000 |
| Total project cost | $16,200,000 | $25,000,000 |
I’ve used a roughly 55% LTV first mortgage since that is not uncommon for stronger transactions. The SBA does not limit the LTV on the first mortgage, but it usually runs between 50% and 60%. Larger loan amounts are also possible with more equity or larger down payments.
FY2026 Manufacturer Fee Waiver — In Effect Now, Regardless of Whether This Bill Passes
- 7a loans to manufacturers of $950,000 or less: 0% upfront guaranty fee — no fee at all.
- 504 loans for manufacturers, including refinancing: no upfront SBA fee and no annual service fee in FY2026 (through September 30, 2026).
Like any commercial loan, other closing costs still apply — but these waivers are meaningful savings. A manufacturer closing a deal before September 30, 2026 gets both the current 504 manufacturer terms and the fee waiver simultaneously.
How Do the New Loan Limits Help Manufacturers Who Want to Expand or Acquire?
Under the current rules, the typical maximum SBA loan amount — whether a 7a first loan or 504 second — is $5 to $5.5 million. This cap has often constrained small manufacturers whose expansion projects or equipment needs exceed the limit. The Made in America Manufacturing Finance Act directly addresses this gap by doubling the maximum loan specifically for small manufacturing businesses. In practical terms:
SBA 7a loans: Qualifying manufacturers could secure up to $10 million (or more) in SBA-guaranteed 7a financing, versus the prior $5 million limit. The 7a program is versatile — it can fund all of the following:
- Land/real estate purchase
- Construction (especially ground-up projects and projections-based ground-up construction)
- Business acquisitions
- Business expansions
- Equipment purchases
- Vehicles
- Working capital
- Inventory
- Other small business needs
With a higher cap, manufacturers can finance larger initiatives — purchasing land and constructing a new manufacturing facility, launching a new product line, or acquiring a competitor and their entire production facility — all under one loan. This fills a critical financing gap for loans in the $5–10 million range that are often hard to obtain from banks without an SBA guarantee.
* How some SBA lenders already exceed $5 million on the 7a today: A small number of lenders add an unguaranteed 2nd loan behind a guaranteed $5 million SBA 7a — typically $1–4 million depending on the lender and transaction strength. If the Made in America Manufacturing Finance Act passes, small manufacturers would have access to at least $10 million in SBA 7a financing, or possibly more if those same lenders continue stacking behind the new higher amounts.
** The no-down-payment acquisition feature: The SBA 7a allows you to purchase another business in the same industry (same NAICS code) with no down payment. If the new higher limit becomes law, small manufacturers would have even more SBA capacity to grow by acquisition or open new locations — especially helpful for those currently at or near the $5 million eligibility ceiling.
SBA 504 loans: The 504 program is a two-loan structure — a conventional first mortgage and an SBA-guaranteed 2nd mortgage — typically used for major fixed assets like real estate and heavy equipment. If this bill passes, the SBA-guaranteed 2nd loan limit rises to $10 million for eligible manufacturers. Previously, 504 loans for manufacturers had a cap of $5–5.5 million for the SBA-backed portion. With the higher limit, a manufacturer could finance projects on a much larger scale — constructing a new plant, purchasing and installing high-tech machinery — using the 504’s low-down-payment, mostly fixed-rate financing. A dramatic increase in the loan limit would recognize that the cost of competing in modern manufacturing — from advanced machinery to expanded production space — often exceeds the current SBA max loan amounts.
What Options Do Non-Manufacturers Have for Larger SBA Loans Right Now?
What’s possible today without being a manufacturer:
- $6–9M via layered 7a: Lenders that offer the two-loan 7a structure with an unguaranteed 2nd loan are already doing this for strong transactions. You can get close to $10M today.
- $10–20M+ via 504: If you have a real estate or machinery/equipment transaction, the 504 program can currently support projects in the $10–20 million range for all business types.
- Piggyback a 7a behind a 504 for additional funds covering: working capital, inventory, soft costs/start-up liquidity, moving costs for the business or heavy equipment, debt refinancing (if eligible), and sometimes FF&E if not covered elsewhere.
The key: you currently cannot exceed $5 million in combined SBA-guaranteed debt — but for 504 transactions, only the 504 second is actually guaranteed by the SBA. So practically speaking, the following structure is possible today for any borrower:
Hypothetical — business moving to a new location:
504 first loan or mortgage: [lender portion — unguaranteed]
504 2nd loan or mortgage: $5,000,000 (SBA-guaranteed)
7a loan for working capital, inventory, soft costs: $500,000 (SBA-guaranteed)
Combined SBA-guaranteed exposure: $5,500,000 — within current limits
I don’t think many business owners know the true value of these programs unless they have a real need and find a savvy lender who has been there and done that — because the level of creativity that’s possible is unlike anything I know of on the conventional/traditional bank side.
Who Qualifies as a “Small Manufacturer” Under This Bill?
Truly large businesses cannot tap these higher loan limits — the Act targets small U.S.-based manufacturers. But the definition of “small” is actually quite large and often means mid-sized. The criteria include:
⚠️ The Stricter Requirement: U.S. Production Only
A unique condition in this bill is that the $10 million cap only applies to manufacturers with all production facilities located in the United States. If a company’s manufacturing operations rely even in part on facilities abroad — a subsidiary, a contract manufacturing arrangement, a joint venture — it does not qualify for the increased loan size. This is more restrictive than the existing SBA manufacturer category, which simply requires that the primary business is manufacturing (NAICS 31–33). A business with any overseas production keeps access to the existing $5.5 million 504 manufacturer limit — it just cannot access the new $10 million ceiling.
Industry classification: The business must fall under manufacturing NAICS codes 31, 32, or 33 — covering food processing, fabricated metal, machinery, high-tech manufacturing, and more. It needs to be a bona fide manufacturer producing goods.
Small business size standard: It must meet the SBA’s small business size standards for its industry. Manufacturing firms are generally considered small if they have 500 or fewer employees, though certain categories go higher — up to 1,500 employees for sectors like aircraft or semiconductors. In practice, about 98% of all U.S. manufacturing firms qualify as small businesses under the SBA’s definition. Virtually all but the very largest manufacturers would qualify.
Manufacturing businesses that could benefit from the new higher loan limits range from metal fabrication shops and food product makers to furniture, textiles, electronics assemblers, machinery producers, and more — any U.S. manufacturer that qualifies as a small business and produces exclusively in America.
What Are the Other Key Benefits Beyond Higher Loan Amounts?
Financing larger investments in equipment and facilities. By raising the SBA loan ceiling to $10 million, the Act would enable small manufacturers to finance major investments previously out of reach — buying expensive machinery, automating production lines, expanding or modernizing a factory, or constructing a new facility, all in a single loan package. With the current $5 million cap, many of these projects were only partially funded or not funded at all.
Supporting growth and competitiveness. The higher limit directly addresses the reality that the cost of competing in manufacturing has risen — whether due to advanced technology, larger space requirements, or supply chain shifts. Lawmakers have acknowledged that the previous $5 million cap is outdated in today’s industrial landscape. Small manufacturers will be better equipped to fulfill large orders, enter new markets, or ramp up production — effectively leveling the playing field against larger companies and importers.
Encouraging domestic production and reshoring. Because the $10 million loans are reserved for companies manufacturing entirely in the U.S., the Act creates a powerful incentive for local production — rewarding firms that have kept operations onshore and encouraging others to bring production back. Strategically, it could strengthen domestic supply chains, create U.S. manufacturing jobs, and reduce reliance on imports.
Improved refinancing options. Recent SBA rule changes have broadened refinancing eligibility and removed certain caps, allowing manufacturers to refinance debt even if the project has no expansion component (which was a previous requirement for a 504 refinance). A manufacturer paying a high rate to a private lender could refinance into an SBA-guaranteed 7a loan at a lower rate, extending the repayment term up to 10 years for equipment or working capital, or 25 years for real estate. If the Act becomes law, refinanceable amounts could reach $10 million or more.
Current Legislative Status
House passed unanimously: December 1, 2025 | Senate received/placed on calendar: December 4, 2025 | Senate companion bill: S. 1555 | Status as of April 2026: Awaiting Senate vote
Frequently Asked Questions
Has the Made in America Manufacturing Finance Act passed?
As of April 2026, the bill passed the U.S. House unanimously (December 1, 2025) and was placed on the Senate calendar on December 4, 2025. It has not yet passed the Senate. A companion bill (S. 1555) was introduced in the Senate with similar provisions. Full bill text is available at congress.gov. This post will be updated when there is a Senate vote.
Do I have to manufacture everything in the U.S. to qualify for the new $10 million limit?
Yes — under the bill’s definition, all production facilities must be located in the United States. This is more restrictive than the existing SBA manufacturer category. A business with any overseas production would not qualify for the new $10 million ceiling — though it would still qualify for the existing $5.5 million 504 manufacturer limit under current rules, as long as its primary business is manufacturing (NAICS 31–33).
What is the maximum SBA 504 project size for a manufacturer today?
Under current law, a qualifying manufacturer can access a $5.5 million SBA 504 second loan per project. With a roughly 55% LTV first mortgage, that corresponds to approximately $16.2 million total with 10% down. And that limit can be used on multiple separate projects simultaneously — meaning a manufacturer with three projects could have over $40 million in total 504-financed projects right now, without waiting for this bill.
Can a manufacturer combine the SBA 7a and 504 programs on the same transaction?
In some structures, yes. A 7a can cover working capital, inventory, soft costs, or other purposes while a 504 handles the real estate and equipment. The key constraint is that combined SBA-guaranteed debt cannot exceed $5 million under current law (or $10 million for manufacturers if this bill passes). Because only the 504 second is SBA-guaranteed in a 504 structure, there is meaningful flexibility here. These layered structures require a lender experienced in both programs.
Is the FY2026 manufacturer fee waiver separate from this bill?
Yes — completely separate. The SBA announced fee waivers for manufacturers (NAICS 31–33) for FY2026, running through September 30, 2026. That waiver covers upfront guaranty fees and annual service fees on both 7a and 504 loans for qualifying manufacturers. It is in effect now, regardless of whether the Made in America Manufacturing Finance Act passes the Senate.
What if I’m not a manufacturer — can I still access larger SBA loans?
Yes. SBA 504 projects in the $20–$25 million range are available to all business types today — not just manufacturers. A small number of SBA 7a lenders will go to $7–9 million for strong transactions by adding an unguaranteed second behind the $5 million SBA first. You can also piggyback a 7a behind a 504 for additional working capital, inventory, or soft costs, as long as combined SBA-guaranteed exposure stays within current limits. The creativity available in these programs is genuinely underappreciated.
Commercial lending is complicated. SBA lending adds another layer of rules — and the max loan amounts are one of the most confusing aspects of this type of financing, because for reasons described above, the maximums are not the maximums. That said, SBA loans can be a huge advantage: higher leverage, longer terms and amortization, and often much more flexible underwriting on credit and cash flow. If these higher limits go through, it should help a lot of U.S. manufacturers.
If you’re a manufacturer or business owner and want to know more about the new possible loan limits — or more importantly, what’s possible right now — feel free to reach out to me at or call: 1-800-414-5285.
About the Author
John King
Founder, Green Commercial Capital
John King is a commercial financing consultant and SBA loan specialist based in the Metro Atlanta area. He founded Green Commercial Capital in 2009 with a straightforward mission: help business owners nationwide navigate the complexity of SBA financing and connect them with the right lender — without adding cost to the transaction. John has spent 17 years working on SBA 7a and 504 transactions ranging from complex business acquisitions to specialty property types including RV parks, self-storage, and manufacturing facilities.
Related Posts You May Find Useful
- What Is the Maximum SBA Loan Amount? (All Programs, All Structures) — the full breakdown of how loan limits work across 7a, 504, Green 504, and the two-business NAICS rule
- How to Get $10 Million in SBA 7a Loans — The Two-Business NAICS Rule — how manufacturers with two businesses in different NAICS codes can have $10M in SBA loans simultaneously right now
- Machine Shop Acquisition Financing: SBA 7a & 504 for Buyers — financing structure for manufacturers buying an existing operation in the $2M–$5M range
- SBA 504 Loan Overview — full program details, eligible uses, and how the two-loan structure works